PUDHARI PUBLICATIONS PRIVATE LIMITED,KOLHAPUR vs. INCOME TAX OFFICER, ,TDS, KOLHAPUR, KOLHAPUR

In the result, both appeals of the assessee in ITA

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.10 To 12/Pun/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2021-22 Pudhari Publications Private Ltd., The Ito, Tds, 2318, C Ward, Pudhari Bhavan, V Kolhapur – 416003. Bhausingji Road, S Kolhapur – 416002. Pan: Aadcp2453Q Appellant/ Assessee Respondent /Revenue Assessee By Shri S.N.Puranik – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 19/02/2024 Date Of Pronouncement 20/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 10.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.10/Pun/2024 For A.Y.2019-20, As A Lead Case. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal :

TDS on Salary itself is not tenable in law. Further it is requested that: - 1. The assessee craves leave to amend, alter or delete any of the above grounds of appeal. 2. It is prayed that the above claims and allowances be allowed.” Submission of ld.Authorised Representative(ld.AR) : 2. The ld.Authorised Representative(ld.AR) for the Assessee submitted that assessee

PUDHARI PUBLICATIONS PRIVATE LIMITED,KOLHAPUR vs. INCOME TAX OFFICER, TDS, KOLHAPUR, KOLHAPUR

In the result, both appeals of the assessee in ITA

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.10 To 12/Pun/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2021-22 Pudhari Publications Private Ltd., The Ito, Tds, 2318, C Ward, Pudhari Bhavan, V Kolhapur – 416003. Bhausingji Road, S Kolhapur – 416002. Pan: Aadcp2453Q Appellant/ Assessee Respondent /Revenue Assessee By Shri S.N.Puranik – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 19/02/2024 Date Of Pronouncement 20/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 10.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.10/Pun/2024 For A.Y.2019-20, As A Lead Case. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal :

TDS on Salary itself is not tenable in law. Further it is requested that: - 1. The assessee craves leave to amend, alter or delete any of the above grounds of appeal. 2. It is prayed that the above claims and allowances be allowed.” Submission of ld.Authorised Representative(ld.AR) : 2. The ld.Authorised Representative(ld.AR) for the Assessee submitted that assessee

PUDHARI PUBLICATIONS PRIVATE LTD,KOLHAPUR vs. INCOME TAX OFFICER, TDS, KOLHAPUR, KOLHAPUR

In the result, both appeals of the assessee in ITA

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.10 To 12/Pun/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2021-22 Pudhari Publications Private Ltd., The Ito, Tds, 2318, C Ward, Pudhari Bhavan, V Kolhapur – 416003. Bhausingji Road, S Kolhapur – 416002. Pan: Aadcp2453Q Appellant/ Assessee Respondent /Revenue Assessee By Shri S.N.Puranik – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 19/02/2024 Date Of Pronouncement 20/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 All Dated 10.11.2023. Since Issue Involved Is Same, All These Appeals Were Heard Together & Decided By This Consolidated Order. We Treat Appeal In Ita No.10/Pun/2024 For A.Y.2019-20, As A Lead Case. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal :

TDS on Salary itself is not tenable in law. Further it is requested that: - 1. The assessee craves leave to amend, alter or delete any of the above grounds of appeal. 2. It is prayed that the above claims and allowances be allowed.” Submission of ld.Authorised Representative(ld.AR) : 2. The ld.Authorised Representative(ld.AR) for the Assessee submitted that assessee

JOHN DEERE INDIA PVT. LTD,PUNE vs. CIT(A) , DEHI

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2477/Pun/2024 िनधा"रण वष" / Assessment Year: 2014-15 John Deere India Pvt. Ltd., V The Commissioner Of Tower 14, Cyber City, S Income Tax(Appeals), Magarpatta City, Hadapsar, Nfac, Delhi. Pune – 411013. Pan: Aaacj4233B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 22/01/2025 Date Of Pronouncement 27/01/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15; Dated 27.09.2024. The Assessee Has Raised The Following Grounds Of Appeal : “1] The Learned Cit(A) Erred In Using Same Statement Of Facts & Findings For Assessment Years 2011-12 & 2014-15 Whereas The Statement Of Facts & Findings Are Not Relevant At All For Assessment Year 2014-15. Ita No.2477/Pun/2024 [A]

TDS and amount of Rs. 1,574,817 being deducted in the name of John Deere Equipment private Limited to which has merged with the assessee company with effect from 1 April 2010. 5. The learned A.O. failed to give interest u/s 244A of the Income Tax Act, 1961 which the assessee was entitled

DY. COMMISSIONER OF INCOME TAX CIRCLE-1(1), PUNE, PUNE vs. ENTERPRISEDB SOFTWARE INDIA PRIVATE LIMITED, PUNE

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamoreआयकर अपील सं. / Ita No. 989/Pun/2023 & Co No. 008/Pun/2024 निर्धारण वर्ा / Assessment Year : 2017-18 Dy. Commissioner Of Income Tax, Central Circle-1(1), Pune . . . . . . . अपीलार्थी / Appellant

TDS, the Ld. AO disallowed the License fees u/s 40(a)(i) of the Act and assessed the total income accordingly u/s 143(3) of the Act. ITAT-Pune Page 2 of 8 DCIT Vs Enterprises Software India Pvt. Ltd. ITA No. 989/PUN/2023 & Co No. 008/PUN/2024 2.3 Aggrieved assessee carried the matter in an appeal u/s 246A(1

SALASAR WAREHOUSING PRIVATE LIMITED,PUNE vs. INOCME TAX OFFICER, WARD-6(1), PUNE, PUNE

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri Partha Sarathi Chaudhuryand Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.59/Pun/2023 िनधा"रण वष" / Assessment Year : 2020-21 Salasar Warehousing Private The Income Tax Officer, Limited, V Ward-6(1), Pune. F-2,Warehouse, Sr.No.20/2A, S Near Mundhwa Bridge, Kharadi, Pune – 411014. Pan: Aamcs4834C Appellant/ Assessee Respondent /Revenue Assessee By Shri Sarvesh Kandelwal – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 27/09/2023 Date Of Pronouncement 30/11/2023

TDS payment of Rs.15,21,817/-, Employers contribution to PF of Rs.64,846/-, Employers contribution to ESI of Rs.16,045/-, Professional Tax of Rs.9,750/- and Bonus to employees of Rs.4,37,107/-, is not in accordance with the Act and the same be deleted. Just and proper relief be granted. 2. The appellant prays to be allowed

SHRIMADURJIT SEVA KENDRA,PUNE vs. THE ITO, WARD 8(3), PUNE, PUNE

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2276/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Shrimadurjit Seva Kendra, V The Income Tax Officer, S.No.117/1, Chowisawdi, S. Ward-8(3), Pune. Haveli, Pune – 412105. Pan: Absfs4340L Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Amit Bobde –Cit(Dr) Date Of Hearing 19/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Appeal Has Been Filed By The Assessee Against The Order Of Ld.Additional/Joint Commisioner Of Income Tax(Appeal), Panaji Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 31.07.2025. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Addl./Jt.Cit(A), Panaji Erred In Law & On Facts In Dismissing Appellant'S Appeal Without Granting Sufficient Opportunity Of Being Heard. Appellant Assures To Make All The Compliances Before The

TDS, Ghaziabad; erred in law and on facts in levying interest u/s 220(2) of the ITA, 1961 amounting to Rs.18,200/-. 5. Appellant craves leave add / alter / modify / delete / amend all / any of the Grounds of Appeal.” 2. At the outset of hearing, no one appeared on behalf of the assessee. No written submission was filed. Submission of ld.Departmental

ELECTRONICA FINANCE LIMITED,PUNE vs. D.C.I.T, CIRCLE-1(1), PUNE, PUNE

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2629/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 Electronica Finance Limited, V The Dcit, “Audumber”, 101/1, S Circle-1(1), Pune. Erandwane, Dr.Ketkar Road, Pune – 411004. Pan: Aaace4577B Appellant/ Assessee Respondent / Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 22/04/2025 Date Of Pronouncement 24/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961; Dated 19.12.2023 For Assessment Year 2018-19. The Assessee Has Raised The Following Grounds Of Appeal :

1. The learned CIT(A), NFAC erred in law and on facts in confirming the total income at Rs.34,61,09,145 instead of returned income of Rs.31,11,65,380/- 2. The learned CIT(A), NFAC erred in law and on facts in not providing sufficient reasonable opportunity of being heard to the appellant to submit the details / information

RAVINDRA BHAUSAHEB MADHAVAI ,NASHIK vs. ITO WARD 1(1), NASHIK

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1737/Pun/2024 "नधा"रण वष" / Assessment Year : 2013-14

1) dated 20.10.2014 and 19.11.2015, the assessee submitted his written submissions. Based on the written submissions, the Assessing Officer observed that in the Audit Report it was stated that the assessee is in the business of Civil Contractor whereas in the written submission it is stated that he is in the business of Builders and Developers. It was found

DEMAG CRANES AND COMPONENTS GMBH,PUNE vs. ACIT(IT)CIRCLE 1, PUNE, PUNE

The appeal is ALLOWED FOR STATISTICAL PURPOSE

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 1115/Pun/2023 निर्धारण वषा / Assessment Year : 2011-12

TDS thereon. In the evince thereof, the appellant was called upon file return for AY 2011-12. Consequently, the case of the appellant was reopened by service of notice u/s 148 of the Act and an assessment order u/s 147 r.w.s. 143(3) of the Act was passed by assessing the total income of the appellant

RAJSHREE SINGH,PUNE vs. ITO WARD 14(5) PUNE, PUNE

In the result, the appeal of the assessee is allowed

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

section 271(1)(C) under which the assessee has committed default attracting penalty u/s 271(1)(C), hence the penalty may please be cancelled. 4) The lower authorities erred in levying penalty u/s 271(1)(C) Rs 362431 and it may please be deleted/cancelled. 5) The Appellant seeks leave to add, alter, amend or drop any of grounds taken above

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 PAN: AAATB4383K (Appellant) (Respondent) Assessee by : Shri Kishor B Phadke Department by : Shri Amol Khairnar, CIT-DR Date of hearing : 11-12-2025 Date of pronouncement : 28-01-2026 O R D E R PER R.K. PANDA, V.P: This appeal filed by the assessee is directed against the order dated

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

251 have held that weighted deduction is\nto be allowed under section 35(2AB) of the Act after the establishment of facility.\nHowever, section does not mention any cutoff date or particular date for eligibility\nto claim deduction. The Hon'ble High Court held as under \"8 The Tribunal has\nconsidered the submissions made on behalf of the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

251 have held that weighted deduction is\nto be allowed under section 35(2AB) of the Act after the establishment of facility.\nHowever, section does not mention any cutoff date or particular date for eligibility\nto claim deduction. The Hon'ble High Court held as under \"8 The Tribunal has\nconsidered the submissions made on behalf of the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLIGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

251 have held that weighted deduction is\nto be allowed under section 35(2AB) of the Act after the establishment of facility.\nHowever, section does not mention any cutoff date or particular date for eligibility\nto claim deduction. The Hon'ble High Court held as under \"8 The Tribunal has\nconsidered the submissions made on behalf of the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, AURANGABAD, AURANGABAD vs. ENDURANCE TECHNOLOGIES LIMITED, AURANGABAD

In the result, all the appeals filed by the Revenue are dismissed

251 have held that weighted deduction is\nto be allowed under section 35(2AB) of the Act after the establishment of facility.\nHowever, section does not mention any cutoff date or particular date for eligibility\nto claim deduction. The Hon'ble High Court held as under \"8 The Tribunal has\nconsidered the submissions made on behalf of the assessee

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE -2(1),, PUNE vs. M/S. EMCURE PHARMACEUTIALS LTD,, PUNE

In the result, both the appeals are dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

section 251(1) of the Act. 3. Tersely stated, the factual position for the assessment year 2011-12 is that the assessee gave certain unsecured loans to its subsidiary company, namely, Emcure Pharmaceuticals, USA Inc. The Foreign company deducted tax at source on the amount of interest on loan credited to the assessee, which was eventually paid in a later

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE -2(1),, PUNE vs. M/S. EMCURE PHARMACEUTIALS LTD,, PUNE

In the result, both the appeals are dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

section 251(1) of the Act. 3. Tersely stated, the factual position for the assessment year 2011-12 is that the assessee gave certain unsecured loans to its subsidiary company, namely, Emcure Pharmaceuticals, USA Inc. The Foreign company deducted tax at source on the amount of interest on loan credited to the assessee, which was eventually paid in a later